Sealed forensic record · Report #702

What's for sale here is a dated, hashed snapshot of a defendant's live tracking behavior, marketing representations, and consent UX, sealed under FRE 901 chain of custody on the day we captured it. Defendants rewrite their policies and pull their pixels the moment a complaint lands — this record is the only proof of what the site was doing before.

Case at a glance

LocationHQ: New York

Nat'l classScope varies — ADA Title III

ArbitrationClass-viable — browsewrap, likely unenforceable

ClaimsADA Title III / Robles v. Domino's (9th Cir.) / Unruh Civil Rights Act / NY State Human Rights Law

**ADA Title III Web Accessibility / Robles v. Domino's** A consumer-facing platform marketing hair growth supplements makes unsubstantiated health claims while maintaining a website with significant accessibility barriers. The site contains 9 accessibility violations across 4 pages scanned, preventing users with disabilities from accessing product information and purchasing pathways. The defendant also deploys 458 third-party trackers, raising privacy concerns alongside the accessibility failures. Captured representations include: "#1 Dermatologist-Recommended Hair Growth Supplement Brand"; "[DEFENDANT] Women's Balance is the only hair growth supplement with published clinical studies in menopausal women with hair thinning"; "This formula is proven to improve hair growth by targeting key root causes of thinning, such as hormones and aging"; "Start growing in as little as 3-6 months"; "70% of women saw overall improvement in their hair after 6 months"; "64% of women saw less shedding after 6 months"; and "[DEFENDANT] is the first and only hair growth supplement to be NSF Certified for Sport®, the gold standard for MLB—with testing against 290+ athletic banned substa." Sealed PDF chain-of-custody: 29 screenshots across 15–25 pages.

Case theory: ADA Title III / Robles

What you receive

Sealed PDF report (typical 15–28 pp) with full chain of custody — SHA-256 + RFC 3161 timestamps on every artifact
Verbatim binding representations with Wayback-anchored class-period bounds
Full network capture: every tracker fire, sensitive transmission, identity-sync event
Wrap classification: BROWSEWRAP / CLICKWRAP / SIGN-IN-WRAP verdict + Specht-line alignment
Per-circuit case-law alignment (LIKELY_UNENFORCEABLE / LIKELY_ENFORCEABLE / JURISDICTIONALLY_DEPENDENT)
Defendant name + domain — revealed at purchase

✓ Prior-litigation check: clear. No prior plaintiff-class filing found against this defendant on this theory (CourtListener federal + web search of state courts, checked 2026-06-07).
No prior plaintiff-class filing found against this defendant in this lane.